oddFlex Games, Inc. – Privacy Policy

Updated: August 27, 2022

This Privacy Policy describes the personal data handling policies of oddFlex Games, Inc. (“oddFlex” or “we” or “us”), including the following:
What personal data we collect from oddFlex’s online and mobile applications, services and our website at www.oddflex.com (collectively, the “Services”):

What personal data we collect from oddFlex’s online and mobile applications, services and our website at www.oddflex.com (collectively, the “Services”);
How we use the data;
With whom we may share the personal data;
Legal basis for processing the data;
Storage and security of your data;
Users outside the United States; and
Links to other sites;
Privacy Policy updates; and
Contact Information.
Your Privacy Rights, Choices and Disclosures, including those for Europe and California;

1. Personal Data We Collect or Process

The Services capture some information about you automatically utilizing background local storage and session storage technologies (“Cookies”). Cookies are small files or other pieces of data which are downloaded or stored on your computer or other device, that can be tied to information about your use of the Services (including certain third party services and features offered as part of our website). Examples of information of this type are your IP address, the browser you are using, the operating system you are using, the pages on the website that you visit and details of your transaction activity, such as the amount, date and time for each transaction. When we use Cookies, we may use “session” Cookies that last until you close your browser or “persistent” cookies that last until you or your browser delete them. You may change your browser setting to decline the use of Cookies.
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We use Google Analytics, a web analytics service of Google Inc. (“Google”) which uses cookies to identify the frequency of use of certain areas of our website and to identify preferences. For more information regarding how Google collects, uses, and shares your information please visit http://www.google.com/policies/privacy/partners/. The information regarding your use of this website that is generated by the cookie (including your truncated IP address) is transferred to a Google server in the United States and stored there. Google will use this information to analyze your use of the Services, compile reports on activity for us, and perform further services associated with website use and Internet use. Google may also transmit this information to third parties where required by law or to the extent that third parties process these data on behalf of Google. You can deactivate Google Analytics using a browser add-on if you do not wish the analysis to take place. You can download the add-on here: https://tools.google.com/dlpage/gaoptout?hl=en.
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We operate social media pages on third party networks. When you visit or link to our social media pages, data is processed both by us and the applicable social media provider. Social media providers are unaffiliated with us, and we are not responsible for the content or privacy practices of social media providers. Social media providers have their own terms of use and privacy policies, and we encourage you to review those policies whenever you visit their websites or interact with their platforms.

We may use third-party companies to help us tailor Services content to users or to serve ads or messages on our behalf. These companies may employ cookies and web beacons to measure advertising or messaging effectiveness (such as which web pages are visited, which messages are responded to, or what products are purchased and in what amount). Any information that these third parties collect via cookies and web beacons is not linked (by them) to any personal information collected by us.
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We also collect information that you provide to us voluntarily. oddFlex collects the information that you provide to us when you sign up to receive newsletters, advisories, announcements and invitations and contact us by email. We use this information only to respond to your comments, requests or questions.

While some of our Services may be utilized without the need to create (or be logged into) an account, some of our Services do require registration, such as selling betting information. To create an account we may ask for your email address, phone number (which may be used for two-factor authentication and push notifications), and financial account information.

In the event a user wishes to sell their betting information to another user, the seller will be required to establish a separate seller account, and the seller may be required to submit additional information that oddFlex may request in order to fulfill its compliance obligations.

We do not knowingly collect information from users of our Services under the age of 18 and/or their internet usage, and such persons are not authorized to use the Services. By using the Services, you represent that you are at least 18 years old. You also represent, by accessing or using the Services, that you are of legal age to enter into legal agreements.

2. How We Use The Data

We use the personal data we collect to respond to your inquiries, complete transactions you initiate, provide or enhance the Services you request, perform our contractual obligations, provide updates and other important information related to your activity on and with the Services, inform you of new services or changes in Services, administer the Services, enter into or facilitate contracts for Services, to fulfill legal obligations we have to governmental authorities or other third parties, and for other legitimate business purposes. You will have the opportunity to opt out of any email marketing communications you may receive from us.

3. With Whom We Share Personal Data

We are a provider of services headquartered in the United States, and as such may need to share information with internal personnel and our affiliates located in different geographic locations in order to perform our Services. We may also share your personal data to third parties (within or outside your country of residence) who perform services on our behalf, including without limitation our payment processors, technology providers and professional advisors, including, without limitation, the following:

Amazon Web Services – web hosting and primary storage of application data;
Google Firebase – identity provider for authentication and authorization of user accounts via email or social media platforms. Transactional push messaging to users devices;
WebPurify – profanity filtering on user input;
Segment – data funnel that allows us to easily send data to multiple places;
Snowflake – data analytics platform that allows us to analyze the data;
Braze – marketing platform that allows us to leverage data to create retention marketing campaigns for users;
AppsFlyer – acquisition marketing data platform (Appsflyer may also collect IP address, and general device information); and
ZenDesk – allows users to contact us directly for customer service, and for us to respond to them via email.

In addition to the foregoing, those seeking to sell betting information will be required to share additional information with a separate third party.

While we do not presently do so, we reserve the right to freely utilize and share for marketing, product development and other lawful purposes (possibly for a fee) with actual and potential business partners all information which we collect. It is anticipated that your information will be transmitted across national boundaries, If you desire that we not share any information, please contact us at support@oddflex.com so that we can record your preferences. However, it may not be possible for us to continue provision of services absent such sharing.

We may disclose information (within or outside your country of residence) if we have a good faith belief that disclosure is necessary by law or the legal process, to protect and defend our or others’ interests or property, or to enforce agreements you enter into with us.

Your information may be transferred to another company (within or outside your country of residence) in connection with a merger or in the event that our business is acquired in whole or part by another company.

We may share aggregated and de-identified information with third parties (within or outside your country of residence) for analytical, research or other similar purposes.

We may obtain your written consent from time to time in electronic form by using online agreements or other acknowledgements on the Services, including for any other contemplated uses of your personal data not addressed in this Privacy Policy. Please read all online agreements carefully before accepting them.

4. Grounds for Using Your Personal Data

We rely on the following legal grounds to process your personal information:
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Consent. Some uses of your personal data as described in this Privacy Policy are subject to your consent, such as marketing email communications. To withdraw your consent, please contact us at support@oddflex.com. You may also refrain from providing, or withdraw, your consent for Cookies via your browser and mobile settings.
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Performance of a contract. We may need to collect and use your personal information to enter into a contract with you and to perform Services that you request.

Legitimate Interests. We may use your personal information for our legitimate interests to provide our Services and to improve our Services and the content contained thereon. We may use technical information as described in this Privacy Policy and use personal information for our marketing purposes consistent with our legitimate interests and any choices that we offer or consents that may be required under applicable law.

Compliance with Legal Obligations. We may use your personal information as necessary to comply with our legal obligations.

5. Storage and Protection of Your Personal Data

We retain the personal data we collect for so long as reasonably necessary to fulfill the purposes for which the data was collected and to perform our contractual and legal obligations. Notwithstanding the generality of the foregoing, we store email addresses until the user requests to be unsubscribed or removes themselves through any self-service tools offered to the user.

We do not store payment card information; rather we utilize the Apple and Google payment platforms and payment processors and store only an electronic receipt that sets forth confirming payment details, such as purchase date, what was purchased, the amount of the transaction, and the usernames of the buyer and seller, but not complete payment card information.

We take reasonable administrative, physical and technical precautions to protect your personal data and communications between us. This includes, when required or as we deem appropriate and feasible under the circumstances, encryption and written commitments from third parties that may have access to your data that they will protect the data with safeguards that are substantially equivalent to those used by oddFlex.

No Internet or email transmission is ever fully secure or error free, however. We therefore cannot guarantee absolute security of your data, and we are not responsible for processes and networks that we do not control. Users assume the risk of security breaches and the consequences resulting from them. Please be careful in deciding what information you send to us via email or over the Internet.

6. Your Rights, Choices and Disclosures

Your European Privacy Rights and Choices. If you reside or otherwise find yourself in the territory of Europe, your privacy rights under the European data protection laws include:‍

Transparency and the right to information. Through this policy we explain how we use and share your information. However, if you have questions or need additional information you can contact us any time.

Right of access, restriction of processing, erasure. You may contact us to request information about the personal data we have collected from you and to request the correction, modification or deletion of such personal information, which requests we will do our best to honor subject to any legal and contractual obligations. To make a request or to ask us a question about our data practices, please contact us via email at support@oddflex.com.

Right to withdraw your consent at any time. When we process your personal data based on your consent, you have the right to withdraw it at any time.

Right to object at any time. You have the right to object at any time to receiving marketing or promotional materials from us by either following the opt-out instructions in commercial emails or by contacting us, as well as the right to object to any processing of your personal data based on your specific situation. In the latter case, we will assess your request and provide a reply in a timely manner, according to our legal and contractual obligations. Some non-marketing communications are not subject to a general opt-out, such as communications about transactions and disclosures to comply with legal requirements.

Right to data portability. You have the right to data portability of your own personal data by contacting us.

Right not to be subject to an automated decision, including profiling. We do not make automated decisions using your personal data that may negatively impact you.

Right to lodge a complaint with a supervisory authority. If you consider that the processing of your personal data infringes your privacy rights according the European Privacy regulation, you have the right to lodge a complaint with a supervisory authority, in the member state of your habitual residence, place of work, or place of the alleged infringement.
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California Disclosures.

California “Shine the Light” Information-Sharing Disclosure: California residents may request a list of all third parties with respect to which we have disclosed any information about you for direct marketing purposes and the categories of information disclosed. If you are a California resident and want such a list, please send us a written request by email to support@oddflex.com with “California Shine The Light Rights” in the subject line.
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California Do Not Track Disclosure: We do not respond to Do Not Track browser settings.
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California Consumer Privacy Act Disclosures. oddFlex is not a “business” as defined under the CCPA and therefore not subject to the CCPA.
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General. This section is subject to specific disclosures on privacy rights set forth below. We are committed to facilitate the exercise of your rights granted by the laws of your jurisdiction, which may include the right to request the correction, modification or deletion of your personal information and the right to opt out of the sale of your personal information (as applicable). We will do our best to honor your requests subject to any legal and contractual obligations. If you would like to make a request, cancel your account or request we delete or no longer use your account information to provide you Services, contact us at support@oddflex.com or make changes to any user profile information connected to your account.
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You may opt out of receiving electronic email marketing communications from us by clicking on the “unsubscribe” link on the communication or contacting us at support@oddflex.com. You may change your settings for the app’s push notifications on your device. Some non-marketing communications may not be subject to a general opt-out, such as communications about transactions, disclosures to comply with legal requirements, software updates and other support-related information. If you do not wish to receive any service-related emails from us, you have the option to deactivate your account.

Subject to local law, you may have additional rights under the laws of your jurisdiction regarding your personal data, such as the right to complain to your local data protection authority.

You may be able to disable Cookies through your browser settings, but if you delete or disable Cookies, you may experience interruptions or limited functionality in certain areas of the Services.

7. Users Outside the United States

The Services are controlled and operated from the United States. If you are an individual from the European Union, Canada or any other jurisdiction with laws or regulations governing personal data collection, use, and disclosure that differ from United States laws, please be advised that we may store the information we collect in the United States which is not deemed an “adequate jurisdiction” by the European regulatory authorities. Personal data may also be transferred from the country of your residence to other countries, including the United States.

8. Links to Other Sites

Our Services may contain links to other websites for your convenience or information. These websites may be operated by companies unaffiliated with oddFlex, and we are not responsible for the content or privacy practices of those websites. Linked websites may have their own terms of use and privacy policies, and we encourage you to review those policies whenever you visit the websites.

9. Privacy Policy Changes

We may update this Privacy Policy from time to time and without prior notice to you to reflect changes in our information practices, and any such amendments shall apply to information already collected and to be collected. Your continued use of the Services after any changes to our Privacy Policy indicates your agreement with the terms of the revised Privacy Policy. Please review this Privacy Policy periodically and especially before you provide personal data to us. If we make material changes to this Privacy Policy, we will notify you here, by email or by means of a notice on our home page. The date of the last update of the Privacy Policy is indicated at the top of this Privacy Policy.

10. Questions and Contact Information

oddFlex is located at:
oddFlex Games, Inc.
P.O. Box 221704
Chicago, IL 60622
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Please contact us if you have any questions about our Privacy Policy.

You may contact us by sending correspondence to the foregoing address or by emailing us at support@oddflex.com.